2026 (5) TMI 839

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....fusing to condone the delay in filing the appeal without appreciating that the assessee is a senior citizen and had not received the assessment order dt: 26/07/2021 either by post or email, and it was during the Covid Pandemic period when the assessment was completed and order was passed, without service of notice as per SOP issued by the CBDT. 2. The Learned CIT(A) failed to appreciate that ex parte order u/s 144 r.w.s 147 r.w.s. 144B of the Act was passed without giving due intimation/notice to the assessee who was dislocated due to Redevelopment of his building. 3. The Ld. CIT(A) erred in not adjudicating the case on merits i.e. addition of Rs 41,38,500/- u/s. 56(2)(x) of the Act being the difference between the stamp d....

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....The assessee filed appeal before ld. CIT(A) on 21.04.2024. There was delay in filing appeal. The assessee explained the cause of delay by filing application for condonation of delay. The delay was not condoned by ld. CIT(A) and the appeal was dismissed as unadmitted. The ld. AR of the assessee submits that after excluding the period of severe Covid - 19 pandemic, it was allowed upto May, 2022. The delay was only of 970 days. The assessee has furnished medical certificate along with the application. The delay was not intentional or deliberate. The ld. AR of the assessee prayed that assessee was good case on merit and likely to succeed, if his case is heard on merit. On merit, the ld. AR of the assessee submits that assessee received a new fl....